Conflict Minerals Policy

Effective: January 1, 2016

Oculus recognizes that the extraction, trade, handling and export of cassiterite, columbite-tantelite (coltan), wolframite and gold, and their derivatives tin, tantalum and tungsten, have contributed to armed conflict and human rights abuses in the Democratic Republic of the Congo (DRC) and adjoining countries. These minerals and derivatives are referred to as “conflict minerals.”

In August 2012, the Securities and Exchange Commission adopted a final rule (SEC Rule) regarding disclosure by public companies of the use of conflict minerals originating in the DRC and adjoining countries to the extent that such conflict minerals are necessary to the functionality or production of a product manufactured or contracted for manufacture. The SEC Rule is mandated by Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act and incorporates and leverages the Organisation for Economic Co-operation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the supplements thereto (OECD Guidance) as a framework for conducting conflict minerals-related due diligence.

Oculus supports continued sourcing of conflict-free materials from the DRC and adjoining areas in accordance with the OECD Guidance and the OECD Guidance’s model supply chain policy, including by means of industry-wide programs such as the Conflict-Free Sourcing Initiative, which works to certify conflict-free smelters in the DRC region.

Oculus expects suppliers to source verified, conflict-free material and to have a policy in place to conduct responsible conflict minerals sourcing within their own supply chains that conforms to the OECD Guidance and that complies with the requirements set forth in the Oculus Vendor Standard. Oculus expects suppliers to provide copies of their policies and supporting information as requested.

If a supplier does not meet our expectations, Oculus will work with the supplier, including by leveraging industry-wide programs as appropriate, to build its capacity for conflict-free sourcing. Oculus will continue to monitor global developments and the emergence of additional requirements or standards related to the sourcing of minerals from the DRC and from other regions.